Structure
Explore more
Set-up
Explore more
What activities will the overseas business be performing?
Will these activities create a permanent establishment and therefore a taxable presence in the overseas territory?
Assuming a taxable presence is created, is it best to set up the overseas business as a joint venture agreement, company or a branch of the existing UK business?
How long will this set-up process take and what regulatory and other requirements need to be met?
Are there any trading or other licenses that need to be obtained?
How can locally generated intellectual property be appropriately protected?
Set up
What is the best ownership structure and how will the overseas entity be held from the UK?
What are the overseas territories requirements in terms of shareholdings – are there any restrictions on ownership or minimal capital requirements?
If a subsidiary company is set up, who should hold the shares – the existing UK company, UK individuals or should a holding company be set up to create a worldwide group?
From a tax perspective what are the pros and cons of each option?
Structure
Profit repatriation
Explore more
Many UK businesses that expand overseas will seek to repatriate some or all of their earnings / profits back to the UK.
What is the most efficient way of doing this – via dividends, loan interest and repayments, royalties, management charges or by way of other trading transactions?
Are there any local regulatory restrictions on profit and cash repatriation that need to be considered?
Profit repatriation
Management and control
Explore more
Who will manage and control the activities of the overseas business and who will be the directors?
Where will those people be located and does this cause any additional tax residency issues that require consideration?
Do local country regulations require a local national director or employee to be recruited?
From a tax perspective will there be sufficient commercial substance in the overseas country?
Management and control
Employee transfers and mobility
Explore more
What payroll and employee tax obligations will arise on the transfer or
recruitment of employees abroad and how are these best structured?
Do you need a locally compliant employment agreement?
What visas / work permits do you need to employ foreign nationals?
How employer vs employee friendly is the local country and how difficult is
it to terminate an employee’s employment?
How can double taxation be minimised from an employees’ perspective?
What are the mandatory insurances you will need?
Employee transfers and mobility
Funding
Explore more
How will the overseas business be funded?
Options may include: by subscribing for share capital, a loan from the existing UK business, UK or overseas bank finance, third party investor finance, or a combination of these.
How long does it take to set up a local country bank account?
Are there any currency controls or foreign exchange restrictions that require consideration?
What are the pros and cons of each source of financing and which may be the best from a commercial and tax perspective?
Funding
Withholding tax
Explore more
What withholding taxes will arise under local tax rules on payments of interest, dividends royalties or other payments?
What tax treaty or other reliefs, can be applied for to potentially relieve the withholding tax?
Withholding tax
Transfer pricing
Explore more
What are the local country’s transfer pricing rules?
What benchmarking, documentation and other evidence will be required to demonstrate that transactions are being conducted at a price and on terms that are at arm’s length?
Transfer pricing
On-going compliance
Explore more
What are the local country statutory accounts filing requirements and deadlines?
What are the key reporting requirements and filing deadlines for corporation tax, VAT/sales tax, payroll and other local taxes?
What are the key rates of the tax that will potentially be suffered including corporate, VAT, employer payroll and other local taxes?
On-going compliance
VAT and duty
Explore more
What VAT and duty is payable if you import goods into the overseas location?
Who will bear the cost of these taxes?
What ongoing local VAT compliance requirements are there and who will assist you in meeting these obligations?
Will you need to appoint a fiscal representative in the local country?
VAT and duty
Ten areas of focus - what you should consider, research and seek advice on for successful expansion abroad.
Ten areas of focus - what you should consider, research and seek advice on for successful expansion abroad.
Ten areas of focus - what you should consider, research and seek advice on for successful expansion abroad.
Ten areas of focus - what you should consider, research and seek advice on for successful expansion abroad.
Ten areas of focus - what you should consider, research and seek advice on for successful expansion abroad.